ML17311A628
| ML17311A628 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/03/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17311A627 | List: |
| References | |
| NUDOCS 9502150088 | |
| Download: ML17311A628 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR 'REACTOR REGULATION RELATED TO AMENDMENT NO.
88 TO FACILITY OPERATING LICENSE NO.
NPF-41 AMENDMENT NO.
75 TO FACILITY OPERATING LICENSE NO. NPF-51 AND AMENDMENT NO. 59 TO FACILITY OPERATING LICENSE NO. NPF-74 ARIZONA PUBLIC SERVICE COMPANY ET AL.
PALO VERDE NUCLEAR GENERATING STATION UNIT NOS.
1 2
AND 3 DOCKET NOS.
STN 50-528 STN 50-529 AND STN 50-530
1.0 INTRODUCTION
By letter dated November 30, 1994, the Arizona. Public Service Company (APS or the licensee) submitted a request for changes to the Technical Specifications (TS) for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3
(Appendix 'A to Facility Operating License Nos.
NPF-41, NPF-51, and NPF-74, respectively).
The Arizona Public Service Company submitted this request on behalf of itself, the Salt River Project Agricultural Improvement and Power District, Southern California Edison
- Company, El Paso Electric Company, Public Service Company of New Mexico, Los Angeles Department of Mater and
- Power, and Southern California Public Power Authority.
The proposed changes would relocate Table 3.3-2, Reactor Protective Instrumentation
Response
Times," and Table 3.3-5, "Engineered Safety Features
Response
Times," of TS 3/4.3.1 and 3/4.3.2, respectively, to the Palo Verde Updated Final Safety Analysis Report (UFSAR) in accordance with the guidance provided in Generic Letter (GL) 93-08.
Tables 3.3-2 and 3.3-5 provide the response time limits for the reactor trip system (RTS) and the engineered safety features actuation system (ESFAS) instruments..
The licensee has stated that the next annual update of the UFSAR will include these tables.
The NRC provided guidance to all holders of operating licenses or construction permits for nuclear power reactors on the proposed TS changes in Generic Letter 93-08, "Relocation of Technical Specification Tables of Instrument
Response
Time Limits," dated December 29, 1993.
In addition, the proposed amendments would make administrative changes to two previous TS amendment requests submitted by letters dated June 30,
- 1993, and December 30, 1993, to maintain consistency with the deletion of Tables 3.3-2 and 3.3-5.
Also, the proposed amendments would delete an obsolete footnote on page 3/4 3-17 of the Palo Verde Unit 2's technical specifications.
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2.0 BACKGROUND
In the early 1980s, the NRC staff undertook efforts to address problems related to the content of nuclear power plant technical specifications.
These projects have resulted in the issuance of various reports, proposed rulemakings, and Commission policy statements.
Line item improvements became a mechanism for technical specification improvement as part of the implementation of the Commission's interim policy statement on technical specification improvements published on February 6,
1987 (52 FR 3788).
The final Commission policy statement on technical specification improvements was published July 22, 1993 (58 FR 39132).
The final policy statement provided criteria which can be used to establish, more clearly, the framework for technical specifications.
The staff has maintained the line item improvement
- process, through the issuance of generic letters, in order to improve the content and consistency of technical specifications and to reduce the licensee and staff resources required to process amendments related to those specifications being relocated from the TS to other licensee documents as a
result of the implementation of the Commission's final policy statement.
Section 50.36 of Title 10 of the Code of Federal Regulations establishes the regulatory requirements for licensees to include technical specifications as part of applications for operating licenses.
The rule requires that technical specifications include items in five specified categories:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
In addition, the Commission's final policy statement on technical specification improvements and other Commission documents provide guidance regarding the required content of technical specifications.
The fundamental purpose of the technical specifications, as described in the Commission's final policy statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.
The Commission's final policy statement recognized, as had previous statements related to the staff's technical specification improvement program, that implementation of the policy would result in the relocation of existing technical specification requirements to licensee controlled documents such as the UFSAR.
Those items relocated to the UFSAR would in turn be controlled in accordance with the requirements of 10 CFR 50.59, "Changes, tests and experiments."
Section 50.59 of Title 10 of the Code of Federal Regulations provides criteria to determine when facility or operating changes planned by a
licensee require prior Commission approval in the form of a license amendment in order to address any unreviewed safety questions.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to UFSAR commitments and to take any remedial action that may be appropriate.
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3.0 EVALUATION The licensee has proposed to remove the references to Tables 3.3-2 and 3.3-5 from TS 3.3.1 and TS 3.3.2 and to delete these tables from the TS.
The licensee committed to relocate the tables on response time limits to the UFSAR in the next annual update.
Tables 3.3-2 and 3.3-5 contain the values of the response time limits for the RTS and ESFAS instruments.
The limiting conditions for operation for the RTS and ESFAS instrumentation specify these systems shall be operable with the response times as specified in these tables.
These limits are the acceptance criteria for the response time tests performed to satisfy the surveillance requirements of TS 4.3.1.3 and TS 4.3.2.3 for each applicable RTS and ESFAS trip function.
These surveillances ensure that the response times of the RTS and ESFAS instruments are consistent with the assumptions of the safety analyses performed for design-basis accidents and transients.
The changes associated with the implementation of Generic Letter 93-08 involve only the relocation of the RTS and ESFAS response time tables but retain the surveillance requirement to perform response time testing.
The UFSAR will now contain the acceptance criteria for the required RTS and ESFAS response time surveillances.
Because it does not alter the TS requirements to ensure that the response times of the RTS and ESFAS instruments are within their limits, the staff has concluded that relocation of these response time limit tables from the TS to UFSAR is acceptable.
The staff's determination is based on the fact that the removal of the specific response time tables does not eliminate the requirements for the licensee to ensure that the protection instrumentation is capable of performing its safety function.
Although the tables containing the specific response time requirements are relocated from the technical specifications to the UFSAR, the licensee must continue to evaluate any changes to response time requirements in accordance with 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (I) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
The staff's review concluded that 10 CFR 50.36 does not require the response time tables to be retained in technical specifications.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure response times, for RTS and ESFAS systems are retained due to those systems'mportance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of specific response time requirements for the various instrumentation channels and components addressed by Generic Letter 93-08 was not required.
The response times are considered to be an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected instrument or component response
- times, where the revisions to those requirements do not involve an unreviewed safety question
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under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
Further, the response time requirements do not constitute a condition or limitation on operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, in that the ability of the RTS and ESFAS systems to perform their safety functions is not adversely impacted by the relocation of the response time tables from the TS to the UFSAR.
In. addition to removing the response times from the TS, the licensee is modifying the TS Bases Sections 3/4.3.1 and 3/4.3.2 to reflect these changes and has stated that the plant procedures for response time testing include acceptance cr iteria that reflect the RTS and ESFAS response time limits in the tables being relocated to the UFSAR.
These changes are acceptable in that they merely constitute administrative changes required to implement the TS change discussed above.
These TS changes regarding relocating instrument response time tables are consistent with the guidance provided in Generic Letter, 93-08 and the TS requirement of 10 CFR 50.36.
The staff has determined that the proposed changes to the TS for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, are acceptable.
The licensee also has proposed changes to two previous TS amendment requests submitted'y letters dated June 30,
- 1993, and December 30, 1993, to maintain consistency with the deletion of Tables 3.3-2 and 3.3-5.
The June 30, 1993, letter submitted a request to revise one entry within TS 3/4.3.2, Table 3.3-5.
Specifically, the auxiliary feedwater turbine driven pump response time limit for a low steam generator level initiating signal was requested to be changed.
Subsequent to the submittal, Generic Letter 93-08 was issued, providing guidance for relocating the entire table from the TS into the UFSAR.
The licensee has requested to withdraw the TS amendment submitted by the June 30, 1993, letter.
The licensee stated that change to the auxiliary feedwater pump response time will be considered under the provisions of 10 CFR 50.59 subsequent to the approval of the TS changes of relocating Tables 3.3-2 and 3.3-5 to the UFSAR.
The staff concludes that this change is acceptable in that it constitutes an administrative change required to implement the TS change as discussed above.
Therefore, the request to withdraw the TS amendment submitted by the June 30, 1993, letter is acceptable.
The December 30, 1993, letter submitted a request to provide. clarification to settings for undervoltage relay trip values for the Class lE 4.16 kV electrical bus for TS 3/4.3.2, Tables 3.3-4 and 3.3-5.
Since the proposed TS relocates Table 3.3-5 from the TS to the UFSAR, the licensee has requested that the December 1993 TS amendment be revised to delete the changes made to Table 3.3-5 and revise the changes made to Table 3.3-4.
The staff is currently reviewing the December 30,
- 1993, proposed TS amendment.
The revised changes as stated in the November 30, 1994, letter, will be used as a
supplement to the December 30, 1994, request.
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